phportune Privacy Policy

Last Updated: May 2026  |  Effective Date: May 2026

1. Introduction

phportune ("phportune," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the phportune platform located at phportune.asia (the "Platform"). This Privacy Policy ("Policy") describes how phportune collects, processes, stores, shares, and protects personal information in connection with your use of the Platform and all associated services.

This Policy is issued in compliance with Republic Act No. 10173, also known as the Philippine Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). By registering for or using the phportune Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with the phportune Terms & Conditions and Responsible Gaming policy, which together govern your use of the Platform.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, phportune acts as the personal information controller ("PIC") with respect to the personal data of its registered players and website visitors. phportune is responsible for determining the purposes and means of processing your personal data collected through the Platform.

phportune operates within the regulatory framework established by the Philippine Amusement and Gaming Corporation (PAGCOR). Our data processing activities are conducted in accordance with PAGCOR requirements and applicable Philippine law.

3. Data We Collect

phportune collects the following categories of personal data from players and Platform users:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth
• Gender
• Nationality and country of residence
• Residential address (including barangay, city/municipality, province)
• Email address
• Philippine mobile number

3.2 Identity Verification Data

• Government-issued photo identification (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys National ID)
• Proof of address documents
• Selfie or facial image for identity verification purposes
• Tax Identification Number (TIN) where required by applicable law

3.3 Financial Data

• GCash or PayMaya account details (mobile number linked to e-wallet)
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where used for transactions
• Partial card details (last four digits, card type) for Visa or Mastercard transactions
• Transaction history including deposits, withdrawals, and gaming activity

3.4 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, login timestamps, and access logs
• Pages visited, games played, and features used on the Platform
• Cookies and similar tracking technologies (see Section 9)

3.5 Communications Data

• Records of communications with phportune customer support via live chat or email
• Feedback, complaints, and dispute records
• Marketing preferences and communication opt-in/opt-out records

4. How We Collect Your Data

phportune collects personal data through the following means:

• Direct collection: Information you provide when registering for an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access or use the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering screening services; payment data from payment processors including GCash, PayMaya, and banking partners.
• Regulatory sources: Information received from PAGCOR or other regulatory bodies in connection with compliance obligations.

5. Purpose and Legal Basis for Processing

phportune processes your personal data for the following purposes and on the following legal bases under the Philippine Data Privacy Act:

Purpose	Legal Basis
Account registration and management	Performance of contract; consent
Identity verification (KYC) and age verification (21+)	Legal obligation; legitimate interest
Processing deposits and withdrawals	Performance of contract
Anti-money laundering (AML) compliance and fraud prevention	Legal obligation; legitimate interest
Responsible gaming monitoring and player protection	Legal obligation; legitimate interest
Customer support and dispute resolution	Performance of contract; legitimate interest
Platform security and technical operations	Legitimate interest
Marketing communications (where opted in)	Consent
Regulatory reporting to PAGCOR and other authorities	Legal obligation
Analytics and Platform improvement	Legitimate interest

6. Sharing Your Personal Data

phportune does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard processing partners, for the purpose of processing your financial transactions.
• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age in compliance with regulatory requirements.
• AML and fraud screening services: Providers engaged to screen transactions and player activity for money laundering, fraud, and other financial crime indicators.
• Game software providers: Licensed game providers whose software is integrated into the phportune Platform, to the extent necessary for game operation and fairness auditing.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where disclosure is required by law or regulation.
• Legal and professional advisors: Lawyers, auditors, and other professional advisors engaged by phportune, subject to professional confidentiality obligations.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required by a valid legal order or where phportune reasonably believes disclosure is necessary to prevent or report a crime.

All third-party service providers engaged by phportune are required to process personal data only in accordance with phportune's instructions and applicable data protection law, and are prohibited from using your data for their own independent purposes.

7. Data Retention

phportune retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, in accordance with PAGCOR requirements and Philippine AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications: Retained for three (3) years from the date of the communication.
• Technical and usage logs: Retained for up to twelve (12) months, unless a longer period is required for security investigation or legal proceedings.
• Marketing preferences: Retained until you withdraw your consent or close your account, whichever is earlier.

Upon expiry of the applicable retention period, phportune will securely delete or anonymize your personal data in accordance with its data disposal procedures.

8. Data Security

phportune implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the phportune Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of the Platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and responding to personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phportune will notify the National Privacy Commission and affected players in accordance with the requirements of the Philippine Data Privacy Act and NPC Circular No. 16-03.

While phportune takes data security seriously, no system is completely immune to security risks. You are responsible for maintaining the security of your phportune account credentials and for notifying us immediately if you suspect unauthorized access to your account.

9. Cookies and Tracking Technologies

phportune uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform. phportune uses the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function, including session management, authentication, and security. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and game display options to improve your experience.
• Analytics cookies: Collect anonymized data about how players use the Platform to help us improve performance and user experience.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the phportune Platform. phportune does not use cookies to serve third-party advertising.

10. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phportune:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of access: The right to request a copy of the personal data phportune holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure or blocking: The right to request deletion or blocking of your personal data where processing is no longer necessary or lawful, subject to phportune's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe phportune has violated your data privacy rights.

To exercise any of these rights, please contact phportune's Data Protection Officer using the contact details in Section 14. phportune will respond to all verified privacy rights requests within fifteen (15) business days of receipt, in accordance with NPC requirements.

11. Minors

The phportune Platform is strictly intended for individuals aged 21 years and above. phportune does not knowingly collect personal data from individuals under the age of 21. If phportune becomes aware that personal data has been collected from a person under 21, it will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the phportune Platform, please contact us immediately using the details in Section 14.

12. International Data Transfers

phportune may transfer your personal data to service providers or partners located outside the Philippines, including in connection with cloud hosting, KYC verification, and game software provision. Where such transfers occur, phportune ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses consistent with the requirements of the Philippine Data Privacy Act and NPC guidelines on cross-border data transfers.

13. Changes to This Privacy Policy

phportune reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. We will notify registered players of material changes by posting the updated Policy on the Platform and, where appropriate, by sending a notification to your registered email address. The date of the most recent revision is indicated at the top of this page. Your continued use of the phportune Platform after the effective date of any changes constitutes your acknowledgment of the revised Policy.

14. Contact and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or phportune's data processing practices, or if you wish to exercise your privacy rights under the Philippine Data Privacy Act, please contact phportune's Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 inside your phportune account dashboard

phportune aims to respond to all data privacy inquiries and rights requests within fifteen (15) business days. If you are not satisfied with phportune's response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.